UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION

WASHI NGTON, DC Regulatory

Docket No. _

______________ INTHE MATTER OF THE PETITION FOR EXEMPTI ON OF: LORETO INNOVATION, INC. FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATION SECTI ONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF THE 3DR & DJI 6 UNMANNED AIRCRAFT SYSTEM PURSUANT TO SECTION 333 OFTHE FAA MODERNIZATION AND

REFORM ACT OF 2012 (PUBLIC LAW 112

- 95)

Submitted on October 18 , 2015 Loreto Innovation LLC. 4200 N. Holton Ave Milwaukee, WI 53212 Tel: 414

- 797

- 1828**TABLE OF CONTENTS**

GLOSSARY OF ABBREVIATIONS ....................................................................

........... .............3
SUMMARY

.................................................................................................................. ........... .......4
IN TRODUCTION AND INTERESTS OF PETITIONER..................................................

........... 4
BACKGROUND ......

....................................................................................................... ........... ....5
BASI S FOR PETITION......................................................................................................

........... .5
NAME AND ADDRESS OF PETITIONER......................................................

..... ...........7
THE SPECIFI C SECTIONS OF 14 C.F.R. FROM WHI CH LORETO INNOVATION SEEKS EXEMPTI ON .......................................................................

.. ............................ ...7
THE EXTENT OF RELIEF LORETO INNOVATION SEEKS AND THE REASON LORETO INNOVATION SEEKS THE RELIEF ...

.................................................... .....11 THE REASONS WHY GRANTING LORETO INNOVATION'S REQUEST WOULD BE I N THE PUBLIC IN TEREST......................................

........................................ .......13
THE REASONS WHY GRANTING THE EXEMPTI ON WOULD NOT ADVERSELY AFFECT SAFETY........................................................................

.. ............................ ......17
SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGI STER......

..... ....31 ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT L ORETO INNOVATION'S REQUEST......................

................................. ..31
CONCLUSION .................................................................................................................3 2AGL Above Ground Level

AOI Area of Interest
AT C Air Traffic Control
AT O Air Traffic Organization
AV Aerial Vehicle
CFR Code of Federal Regulations
COA Certificate of Authorization
FAA Federal Aviation Administration
FAR Federal Aviation Regulation
GCS Ground Control Station
GPS Global Positioning System
LOL Loss of Link
NAS National Airspace System
NOTAM Notice to Airman
PIC Pilot In Command
Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333
SO Safety Observer
SOP Standard Operating Procedures
UA Unmanned Aircraft
UAS Unmanned Aircraft System
VFR Visual Flight Rules
VLOS Visual Line of Site
VMC Visual Meteorological Conditions
VTOL Vertical Takeoff and Landing**SUMMARY**

Loreto Innovation, Inc. seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft S ys tem pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit Lo reto Innovation to operate an Unmanned Aircraft Sy stem (UAS) for the commercial purpose of capturing still imagery , video acquisition and digital 3D data capture (hereinafter referred to as “aerial data acquisition”).
**INTRODUCTION AND INTERESTS OF THE PETITIONER**  Loreto Innovation is one of the fastest growing water technology companies firms in the United States. Lo reto Innovation provides w ater resources to include wate r collection for water sampling, temperature , PH level testing, environmental surve yi ng, mapping, and data collection. Loreto Innovation 's record of technical achievements is enhanced b y a reputation for effective management and personal service. Loreto Innovation ’s clie nts benefit from receiving personal service and local expertise.
L oreto Innovation has recently acquired a 3DR ArduCopter Hexa unmanned aircraft sy stem (hereinafter “3DR ”) and a DJ I Spreading Wings Hexa copter unmanned aircraft (hereinafter named “DJ I” ) Lo reto Innovation has historically used expensive means to acquire aerial information. With the advent of unmanned sy stems (drones) in recent years, Loreto Innovation has become dependent on the capabilities of UAS technology . The use of UAS technology

has a llowed flight i n way s never before capable with conventional fixed wing and rotary vehicles, providing different project perspectives and bridging the gap between traditional land

- based photograph y and traditional manned aerial photograph y. As set forth in this Petition, Loreto Innovation seeks to commerciall y operate its 3DR & DJ I over certain areas of the United States for the purpose of capturing aerial imagery , video acquisition , water sampling , temperature and PH level testing, and 3D data collection.
**BACKGROUND**
Unmanned Aircraft Sy stem: 3DR & DJ I Loreto Innovation seeks an exemption to operate the Lo reto Innovation 3DR & DJ I for compensation or hi re within the NAS. The 3DR is comprised of a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA). The 3DR has a maximum gross tak e - off weight of approximately 6.5 pounds [Ty p ical Operating Payload: 3DR (4 LB) + 55 00mah 3S Batteries (2 LB) + GO PRO Session *& Gimbal (.5 LB) while having a diamet er of 21.65 inches, height of 18 inches, and maximum speed of 20 mph (17.3 7 knots) and a wind tolerance of 15 mph. The 3DR UA is equipped with six plastic propellers, each of which is driven b y a triple bearing, dy namically balanced, brushless electric motor and 18 amp Electronic Speed Control (ESC) unit. The 3DR is powered b y 3S (11 .2V) 35C at 5,5 00mah. Flight times range between 16 minutes and 22 minutes depending on payloads. The DJ I is comprised of a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA).The 3DR & DJ I UAV has a maximum gross tak e - off weight of approximately 8 .5 pounds

[Ty p ical Operating Payload: DJ I (5 LB) + 1100mah 6S Batteries (3 LB) + GO PRO Session *& Gimbal (.5 LB) while having a diamet er of 35.82 inch es, height of 24 inches, and maximum speed of 30 mph (26.07 knots) and a wi nd tolerance of 2 5 mph. The DJ I UA is equipped with six plastic propellers, each of which is driven b y a triple bearing, dynamically balanced, brushless electric motor and 30 amp Electronic Speed Control (ESC) unit. The 3DR is powered b y 6 S (11 .2V) 7 5C at 1 1,0 00mah. Flight times range between 15 minutes and 20 minutes depending on payloads. The 3DR & DJ I that will be operated b y Loreto Innovation will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking.
**BASIS FOR PETITION** Petitioner, L oreto Innovation, Inc., b y and through undersigned counsel, pursuant to the provisions of the Federal Aviation Re gulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012, Section 333, Special Rules for Certain Unmanned Aircraft Sy stems, hereb y petitions the Administrator to operate the 3DR & DJ I in the National Airspace S ys tem (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, Loreto Innovation ’s operation of the 3DR & DJ I meets the conditions of Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Accordingl y, Loreto Innovation requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that onl y apply to aircraft with an airworthiness certificate. Loreto Innovation submits that the requested relief is proper since an equivalent level of safet y will be ensured. Loreto Innovation will use its authorized technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and pra ctices prescribed in the manufacturer’s maintenance manual. Furthermore, Loreto Innovation will document and maintain all maintenance records for the 3DR & DJI

. Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileg es and limitations: Pilot in command, is requested by L oreto Innovation to the extent necessary to allow a Pilot in Command (PI C) who holds a UAV Pilot Certificate that shows 10 hours of simulator, 16 hours of ground school and 16 hours of flight training for a total of 42 hours of training, to conduct the proposed UAS flight operations. L oreto Innovation submits that the conditions and limitations set forth herein will ensure the safety of the NAS, as well as the safet y of persons or property on the ground

. Loreto Innovation seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the 3DR & DJ I does not require an airworthiness certificate in accordance with 14C.F.R. Part 21, Subpart H. As such, Loreto Innovation submits that it w ill ensure that the 3DR &

DJI is in an airworthy

condition, prior to every

flight, by determining that the UAS is in compliance with the 3DR & DJ I Flight Manual, and that the aircraft is in a condition for safe flight. Loreto Innovation also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings, as the 3DR & DJ I UA V will not have a typical barometric altimeter onboard. However, altitude, azimuth, pitch, yaw, heading and speed information of the 3DR & DJI UAV will be provid ed to the PI C via the on

- board On

- Screen Di splay (OSD) module and Naza L ite Global Positioning Sy stem (GPS) which transmits real

- time flight information directly to the PI C’s First Person View (FPV) video monitor mounted to the Ground Control System (GCS ) for active monitoring of flight operations. This altitude information, combined with Loreto Innovation ’s operation of the 3DR & DJ I UAV within vis ual line of sight, at or below 4 00 feet AGL, will ensure a level of safety equivalent to Section 91.121. Add itionally , Loreto Innovation seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. Lo reto Innovation submits that safety will not be affected b y terminating flights of the battery powered 3D R & DJ I after 15

- 20 minutes of continuous flight, which would allow for five minutes of battery power remaining. In accordance with 14 C.F.R. § 11.81, Lo reto Innovation provides the following information in support of its petition for exemption:
A. **Name An d Address Of The Petitioner** 

. The name and address of the Petitioner is: L oreto Innovation, Inc . 4200 North Holton Street, Milwaukee, WI

. The point of contact for this Petition and specific contact information is as follows: Que El

- Amin, 4200 North Hol ton Street, Milwaukee, WI 53212 | Tel: 414

- 797

- 1828 | 414

- 736

- 9036 Email: que @ Lo reto.co
B. **The Specific Sections Of 14 C.F.R. From Which Loreto Innovation Seeks Exemption** 

. **1. Loreto Innovation Seeks Exemption From The Requirements Of Section 61.113(a) And**  **(b).** Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, subsections (a) and (b) prescribe the following, in relevant part: (a) No person who holds a private pilot certificate may act as a pilot in command (PI C) of an ai rcraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as PI C of an aircraft. (b) A private pilot may , for compensation or hire, act as PIC of an aircraft in connection with any business or employ

ment if

— (1) The flight is only

incidental to that business or employ ment; and(2) The aircraft does not carry passengers or property

for compensation or hire. **2. Loreto Innovation Seeks Exemption From The Requirements Of Section 91.7(a).**
Sec tion 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following: (a) No person may

operate a civil aircraft unless it is in an airworthy condition. **3. Loreto Innovation Seeks Exemption From The Requirements Of Section 91.121.**
Sec tion 91.121, entitled Altimeter settings, subsection (a), states the following, in part: (a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating

-- (1) Below 18,000 feet MSL , to

-- (i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft; (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or (iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure ; **4. Loreto Innovation Seeks Exemption From The Requirements Of Section 91.151(b).**  Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b), states the following: (b) No person may

begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fl y after that for at least 15 minutes. **5. Loreto Innovation Seeks Exemption Fr om** **The Requirement Of Section 91.405(a).** Section 91.405, entitled Maintenance required, subsection (a), states the following: Each owner or operator of an aircraft

— (a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter[.] **6. Loreto Innovation Seeks Exemption From The Requirements Of Section 91.407(a)(1).** 

Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration, subsection (a)(1), states the following: (a) No person may

operate any

aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

-- (1) It has been approved for return to service b y a person authorized under § 43.7 of this chapter[.] **7. Loreto Innovation Seeks Exemption From The Requirements Of Sections 91.409(a)(1) And 91.409(a)(2).**  Section 91.409, entitled Ins pections, subsection (a), states the following: (a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had

-- (1) An annual inspection in accordance with part 43 o f this chapter and has been approved for return to service b y a person authorized by § 43.7 of this chapter; or (2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.
**8. Loreto Innovation Seeks Exem ption From The Requirements Of Sections**  **91.417(a) And 91.417(b).** Section 91.417, entitled Maintenance records, subsections (a) and (b), state the following: Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section: (1) Records of the maintenance, preventive maintenance, and alteration and records of the 100

- hour, annual, progressive, and other required or approved inspec tions, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include

-- (i) A description (or reference to data acceptable to the Administrator) of the work performed; and (ii) The date of completion of the work pe rformed; and (iii) The signature, and certificate number of the person approving the aircraft for return to service. (2) Records containing the following information: (i) The total time in service of the air frame, each engine, each propeller, and each rotor.(ii) The current status of life

- limited parts of each airframe, engine, propeller, rotor, and

appliance. (iii) The time since last overhaul of all items installed on the aircraft which are required to b e overhauled on a specified time basis. (iv) The current inspection status of the aircraft, including the time since the last inspection required b y the inspection program under which the aircraft and its appliances are maintained. (v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required. (vi) Copies of the forms prescribed b y § 43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances. (b) The owner or operator shall retain the following records for the periods prescribed: (1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded b y other work or for 1 year after the work is performed. (2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with the aircraft at the time the aircraft is sold. (3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.
**C. The Extent Of Relief Loreto Innovation Seeks And The Reason Loreto Innovation Seeks The Relief.** 
**1. Extent of Relief Loreto Innovation Seeks And The Reason Loreto Innovation Seeks Relief From Section 61.113(a) And (b).**  Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in command, is requested to the extent necessary to allow a PIC who holds a UAV Pilot Certificate that shows 10 hours of simulator, 16 hours of ground school and 16 hours of flight training for a total of 42 hours of training, to conduct the proposed UAS flight operations for compensation.
Th is relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may , for compensation or hire, act as PIC of an aircraft in connection with any business or employ

ment if

- (1) The flight is onl y incidental to that business or employ ment; and (2) The aircraft does not carry passengers or property

for compensation or hire. As set forth more full y below, Lo reto Innovation submits that an equivalent level ofsafet y will be maintained because no PIC will be allowed to operate the 3DR & DJI unless that

PI C has demonstrated, through the UAS training and currency requirements, that the PI C is able to safel y operate the 3DR & DJ I in a manner consistent with the operations specifications as described in this exemption, i ncluding evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures. Further, Loreto Innovation submits that all flights of the 3DR & DJ I , conducted by the PI C pursuant to the grant of this Petition

- (1) will be incidental to Loreto Innovation ’s business; and (2) will not carry

passengers or property for compensation or hire.
**2. Extent of Relief Loreto Innovation Seeks And The Reason Lore to Innovation**  **Seeks Relief From Section 91.7(a).** Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent required to allow Lo reto Innovation to determine that the 3DR & DJ I is in an airworth y condition prior to every flight b y ensuring that the UAS is in compliance with the 3DR & DJ I 6 Flight Manual, and that the aircraft is in a condition for safe flight. Loreto Innovation seeks the requested relief because the 3DR & DJ I does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Lo reto Innovation will ensure that the 3DR & DJ I is in an airworth y condition based upon its compliance with the operating documents (i.e., the 3DR & DJ I Flight Manual) prior to every flight, an d as stated in the conditions and limitations below.
**3. Extent of Relief Loreto Innovation Seeks And The Reason Loreto Innovation Seeks Relief From Section 91.121.**  Relief from Section 91.121 entitled Altimeter settings, may be required to allow flight op erations of the 3DR & DJI , which utilizes GPS equipment and a radio communications telemetry data link to downlink altitude information to the PI C from the UA to the GCS. As more fully

set forth below, safet y will be maintained as a result of the 3DR & DJ I altitude readout via GPS equipment, and Loreto Innovation ’s operation of the 3DR & DJ I UAV within vis ual line of sight, at or below 4 00 feet AGL.
**4. Extent Of Relief Loreto Innovation Seeks And The Reason Loreto Innovation Seeks Relief From Section 91.15**  **1(b).** Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to the extent required to allow flights of the battery powered 3DR & DJ I UAV during daylight hours in visual meteorological conditions (VMC), under v isual flight rules (VFR) conditions, to continue for a total duration of 15

- 20 minutes , which will ensure that the UAV will land with five minutes of battery power remaining. Loreto Innovation seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered 3DR & DJI UAV will severel y constrain the practicality of any aerial acquisition and flight operations that Lo reto Innovation proposes to conduct pursuant to this Petition. Significantl y, as set forth below, the technical specifications of the 3DR & DJI , the 3DR& DJ I Flight Manual, and Lo reto Innovation ’s proposed operating limitations, ensure that Loreto

Innovation will safel y operate the battery powered 3DR & DJ I UAV during daylight hours in VFR conditions, for a total flight duration of 15

- 20 minutes, landing with five minutes of battery power remaining.
**5. Extent Of Relief Loreto Innovation Seeks And The Reason Loreto Innovation Seeks Relief From Sections 91.405(**  **a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b).**  Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & ( a)(2), and 91.417(a) & (b) onl y apply to aircraft with an airworthiness certificate, Loreto Innovation requests relief from these Section s because the 3DR & DJ I does not require an airworthiness certificate. As set forth more fully below, the 3DR & DJI meets the conditions of Section 333 of the FMRA for operation without an airworthiness certificate. Accordingl y, Loreto Innovation will use authorized technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the manufacturer’s maintenance manual. Furthermore, Loreto Innovation will document and maintain all maintenance records for the 3DR & DJ I

. **D. The Reasons Why Granting Loreto Innovation’s Request Would Be In The Public Interest; That Is, How It Would Benefit The Public As A Whole.**  Granting the present Petition will further the public interest b y allowi ng Lo reto Innovation to safel y, efficiently , and economically perform aerial data acquisition commercially , in support of DoD, federal, state, local government and private entities in relation, but not limited to engineering, environmental, energy , technol ogy, planning, transportation, and land development services. Additionally , use of the 3DR & DJ I will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy . Notably , the benefits of Loreto Innovation ’s proposed o peration of the 3DR & DJ I will be realized without implicating any privacy issues.
**1. The Public Will Benefit From Aerial & Underwater**  **Data Acquisition.** Loreto Innovation submits this Petition to commercially operate the 3DR & DJI and perform aerial data acquisition throughout the United States, in support of DoD, federal, state, local government and private entities in relation, but not limited to engineering, environmental, energy , technology , planning, transportation, and land development services. The 3DR & DJ I will provide safe, efficient, and economical aerial data acquisition to capture project specific imagery for project efforts and for use in pursuits. The specific operations that Lo reto Innovation will perform with the 3DR & DJ I demonstrate how the requested exemption will directly benefit the above

- referenced industries and the public. In transportation, the aerial data acquisition performed b y the 3DR & DJ I will be used to acqui re still images, video and other data. These simulations will be u sed for public outreach and comment and will give the public a realistic simulation of a project’s ultimate build out.Underwater data

**2. The Public Will Benefit From Decreased Congestion Of The NAS.** The 3DR & DJ I UAV is battery powered and serves as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery . By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of the 3DR & DJ I would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the air and on the ground. Furthermore, b y reducing the number of manned aircraft operati ng in the NAS, congestion around airports caused b y arriving and departing aircraft will be reduced. The 3DR & DJI UAV does not require an airport to takeoff or land. Li kewise, a reduction of manned aircraft conducting aerial survey

missions would result i n fewer aircraft that must be handled b y air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations. **3. The Public Will Benefit From The Safety And Efficiency Of The 3DR & DJI** 
**.** Conducting aerial acquisitio ns with the 3DR & DJI , instead of manned aircraft, will greatl y benefit the public by drasticall y reducing the levels of air and noise pollution generated during traditional aerial survey flight operations. By

using battery

power and electric motors, the 3 DR & DJ I produces no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal combustion twin engine aircraft that are ty picall y utilized for aerial acquisitions, while burning approximately 20

- 3 0 gallons per hour of leaded aviation fuel. The 3DR & DJ I UAV , while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UA is propelled b y battery powered electric motors, rather than an internal combustion engine

. By using the 3DR & DJ I to perform aerial data capture, the substantial risk to life and propert y in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completely

el iminated. Aside from the lack of flight crew members located onboard the aircraft, the 3DR & DJ I UAV (maximum gross take

- off weight of approximately

10 pounds, a diameter of 35.83 inches and height of 24 inches) has less phy sical potential for collateral d amage to life and property on the ground, and in the air, compared to the manned aircraft that ty picall y conduct aerial acquisitions (weighing approximately

6,500 pounds with a wingspan of approximately 40 feet, a length of 34 feet, and a fuel capacity of 180 gallons). **4. Performing Aerial & Underwater**  **Data Acquisition Operations With The 3DR &**  **DJI Will Benefit The Economy.**  In addition to being safe and efficient, the 3DR & DJI is also an economical alternative to using manned aircraft to conduct aerial a cquisitions. As such, operation of the 3DR & DJ I will allow United States based companies, like Loreto Innovation , to remain competitive and contribute to growth of the U.S. econom y. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory

actions phasing out leaded aviation fuels, U.S. owned and operated companie s must adopt new and alternative technology in order toremain competitive. Operating the battery powered 3DR & DJ I is one such technology that not only allows companies greater operational flexibility compared to manned aircraft, but provides such flexibi lity

without the high operational cost of a traditional manned aircraft. By operating the 3DR & DJI , companies such as Loreto Innovation can remain competitive and profitable, and therefore, provide greater job stability to employees and contractors, whic h will ultimately contribute to growth of the U.S. econom y. Improved financial performance of U.S. companies, through commercial use of the 3DR & DJ I , provides a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and development in order to remain competitive both in the United States and abroad. **5. There Are No Privacy Issues.** Similar to the manned aerial acquisition flight operations that have been conducted for decades, Loreto Innovation ’s proposed operation of the 3DR & DJI will not implicate any privacy issues. Specificall y, the 3DR & DJI will be operated in accordance with all Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F. R. § 91.119. Most significantl y, the 3DR & DJI UAV will not be operated closer than 500 feet to any person, vessel, vehicle, or structure, which is not directl y i nvolved in the operatio n. **E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or**  **How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From Which Loreto Innovation Seeks Exemption.**  **1. Reasons Why The 3DR & DJI**  **Meets The Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA** **) Section 333**

. In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, Loreto Innovation ’s operation of the 3DR & DJ I meets the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security . Specifically , FMRA Section 333 states the following, in part: (a ) In General.

--Notwithstanding any other requirement of this subtitle, and not later than 180 days after the date of e nactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft systems may operate safely in the national airspace system before completion of the plan and rulemaking required by section 332 of this Act or the guidance required by section 334 of this Act. (b ) Assessment of Unmanned Aircraft Systems.

--In making the determination under subsection (a), the Secretary shall determine, at a minimum

-- (1 ) which types of unmanned aircraft systems, if any, as a result of their s ize,weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspace system or the public or pose a threat to national security; and (2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft s ys tems identified under paragraph (1). (c) Requirements for Safe Operation.

--If the Secretary determines under this section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft systems in the national airspace system. In seeking this exemption, Lo reto Innovation submits that the 3DR & DJ I can operate safel y in the NAS pursuant to FMRA Section 333, as demonstrated b y: (a) the characteristics of the 3DR & DJ I ; (b) the pilot certification requirement; and (c) the specific operating limitations. **a. The Specifications Of The 3DR & DJI**  **Demonstrate Its Safe Characteristics.** The 3DR & DJ I does not create a hazard to users of the NAS or the public, or otherwise pos e a threat to national security considering its size, weight, speed, and operational capability.

**i. Technical Specifications Of The 3DR & DJI** 
**.** The technical specifications of the 3DR & DJ I are set forth in the “ 3DR Manual ” & “DJ I Manual“ attached hereto as Exhibit A and B respectfully . Exhibit A & B contain proprietary information and is to be held in a separate file pursuant to 14 C.F.R. § 11.35(b). Exhibits to this Petition contain proprietary information, and in accordance with 14 C.F.R. § 11.35(b), are not to be included in the Federal Docket Management System (FDMS).

**ii. The 3DR & DJI**  **Autonomous Flight And Navigation Modes Enable The UAS To Remain Within A Defined Operational Area.**  A complete description of the autonomous modes and methods of navig ation of the 3DR & DJ I is provided in the , the “ 3DR Manual ” & “DJIManual” attached hereto as Exhibit A & B

. Exhibit A & B contains proprietary information and is to be held in a separate file pursuant to 14 C.F.R. § 11.35(b).

**iii. The 3DR & DJI**  **Is Designed For Automatic Return To Launch In The Event Of Loss Of The Control Link Or Navigation.**  A complete description of the 3DR & DJ I ’s automatic return to launch function in the event of a break in communication or loss of telemetry data is set forth in the the “ 3DR Manual ” & “DJ I Manual “ attached hereto as Exhibit A & B . Exhibit A & B contains proprietary information and is to be held in a separate file pursuant to 14 C.F.R. § 11.35(b). **b. Flight Operations Of The 3DR & DJI**  **Are Limited To The Lin e Of Sight Of A**  **Certificated Pilot in Command With A Safety Observer.** Loreto Innovation will only utilize certificated pilots to act as a pilot in command (PI C) of the 3DR & DJ I . Additionally , a safet y observer will assist all pilots. The PI C must complet e UAV Pilot Certification that shows 10 hours of simulator, 16 hours of ground school and 16 hours of flight training for a total of 42 hours of training. Flights Of The 3DR & DJ I Will Be Conducted Pursuant To Specific Operating L imitations. In seeking th is exemption, Lo reto Innovation proposes to commerciall y operate the 3DR & DJ I for the special purpose of conducting aerial data capture over areas of the United States, pursuant to the following specific operating limitations: 1) Operations authorized by this grant of exemption are limited to the following aircraft described in the operator’s manual which is a hex rotor aircraft weighing less than 30 pounds: 3DR & DJ I Unmanned Aircraft S ys tem. Proposed operations of any other aircraft will require a new p etition or a petition to amend this grant. 2) The UA may

not be flown at an indicated airspeed exceeding 52.14 knots. 3) The UA must be operated at an altitude of no more than 4 00 feet above ground level (AGL), as indicated b y the procedures specified in the operator’s manual. All altitudes reported to ATC must be in feet AGL. 4) The UA must be operated within visual line of sight (VLOS) of the PI C at all times. This requires the PIC to be able to use human vision unaided b y an y device other than corrective lenses. 5) All operations must utilize a visual observer (VO). The VO m ay be used to satisfy

the VLOS requirement, as long as the PIC alway s maintains VL OS capability . The VO and PI C must be able to communicate verbally at all times. The PI C must be designated before the flight and cannot transfer his or her designation for the duration of the flight. 6) The operator’s manual and this grant of exemption must be maintained and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operator’s manual, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operator’s manual. The operator may

update or revise its operator’s manual. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and revised documents if it petitions for extension or amendment. If the operator determines that an y update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for amendment to their exemption. The FAA’s UAS Integration Office (AFS

- 80) may

be contacted if questions arise regard ing updates or revisions to the operator’s manual. 7) Prior to each flight the PI C must inspect the UAS to ensure it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Stationmust be included in the preflight inspection. All maintenance and alterations must be

properl y doc umented in the aircraft records. 8) An y UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics (e.g. replacement of a flight critical component), must undergo a functional test flight in accordance with the operator’s manual. The PIC who conducts the functional test flight must make an entry in the UAS aircraft records of the flight. The requirements and procedures for a functional test flight and aircraft record entry must be added to the operator’s manua l. 9) The preflight inspection must account for all discrepancies, i.e. inoperable components, items, or equipment, not covered in the relevant preflight inspection sections of the operator’s manual. 10) The operator must follow the manufacturer’s UAS ai rcraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements, with particular attention to flight critical components that may not be addressed in the manufacturer’s manuals. 11) Lo reto Innovation must carry out their maintenance, inspections, and record keeping requirements in accordance with the operator’s manual. Maintenance, inspection, and alterations must be noted in the aircraft logbook, including total flight hours, description of work accomplished, and the signatur e of the authorized UAS technician or PI C returning the UAS to service. 12) Lo reto Innovation UAS technicians must receive and document training referenced in the operator’s manual. 13) Each UAS operated under this exemption must comply with all manufacturer Sy stem and Safet y Bulletins. 14) Lo reto Innovation maintenance personnel must make a record entry in the UAS logbook or equivalent document of the corrective action taken against discrepancies discovered between inspections. 15) The PI C must possess at least a UAV Pilot Certificate that shows 10 hours of simulator, 16 hours of ground school and 16 hours of flight training for a total of 42 hours of training. 16) The operator may

not permit any

PIC to operate unless that PI C has demonstrated, through the training and currency requirements set forth in the operator’s manual, that the PI C is able to safely

operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintain ing appropriate distances from people, vessels, vehicles and structures. 17) UAS operations may

not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under spec ial visual flight rules (SVFR) are not authorized.18) The UA S may not operate within 3 nautical miles of the airport reference point as denoted on a current FAA

- published aeronautical chart. 19) The UA S may

not be operated less than 500 feet below or le ss than 2,000 feet horizontally

from a cloud or when visibility is less than 3 statute miles from the PI C. 20) If the UAS loses communications or loses its GPS signal, the UA must return to a pre - determined location within the private or controlled

- access propert y and land, or be recovered in accordance with the operator’s manual. 21) The PI C must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operator’s manual. 22) The PI C is prohibited from beginning a UAS flight unless (considering wind and forecast weather conditions and assuming normal cruising speed) there is enough power to fly to the first point of intended landing prior to utilizing battery reserve power. 23) The operator must obtain an Air Traffic O rganization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under this grant of exemption. This COA will also require the operator to request issuance of a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. 24) All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 C.F.R. Part 47, and have identification (N

Number) markings in accordance with 14 C.F.R. Part 45, Subpart C. Markings must be as large as practicable. 25) Before conducting operations, the radio frequency spectrum used for operation and control of the UA must comply with the Federal Communications Commission (FCC) or othe r appropriate government oversight agency requirements. 26) The documents required under 14 C.F.R. 91.9 and 91.203 must be available to the PI C at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made avail able to the Administrator or an y law enforcement official upon request. 27) The UA must remain clear and yi eld the right of way to all other manned aviation operations and activities at all times. 28) The UAS may

not be operated b y the PIC from any movin g device or vehicle. 29) The UA may

not be operated over congested or densel y populated areas. These areas include but are not limited to the yellow areas depicted on World Aeronautical Charts (WAC), Sectional Aeronautical Charts (Sectionals), or Terminal Area Charts (TAC). Ho wever, aeronautical charts may not reflect pertinent local information. Ultimately , it is the PI C’s responsibility

to maintain the minimum safe altitudes required b y § 91.119.30) Flight operations must be conducted at least 500 feet from all nonparticipating

persons (persons other than the PI C or VO), vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately

and/or;
b. T he aircraft is operated near vessels, vehicles or structures where the land owner/controller has granted permission and the PI C has made a safet y assessment of the risk of operating closer to those objects and;

c. O perations near the PIC or VO do not present an undue hazard to the PI C or VO, per § 91.1 19(a). 31) All operations shall be conducted over private or controlled

- access property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained prior to the beginning of every flight. 32) An y incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined b y the applicable COA must be reported to the FAA’s UAS Integration Office (AFS

- 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov. **2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not Adversel** **y Affect Safety.** Loreto Innovation submits that the equivalent level of safety established by Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the 3DR & DJ I unless that PI C has demonstrated, through the 3DR & DJ I trai ning and currency requirements, that the PI C is able to safely operate the 3DR & DJI in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Considering Loreto Innovation ’s proposed area of operations, and the operating limitations set forth

- above; the parallel nature of private pilot aeronautical knowledge requirements to those of commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to safel y operate the 3DR & DJ I , Lo reto Innovation submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for Loreto Innovation ’s s pecific proposed flight operations. Additionally , the FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g.Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112,

11136, 11138). **3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not Adversely Affect Safety.**  The equivalent level of safety established b y Section 91.7(a) will be maintained beca use prior to every

flight, Loreto Innovation will ensure that the 3DR & DJ I is in an airworth y condition based upon the 3DR & DJ I s compliance with its operating documents (i.e., the 3DR & DJI (CineWing

- 6) Flight Manual), and as stated in the conditions and limitations herein. **4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely Affect Safety.**  The equivalent level of safety established b y Section 91.121 will be maintained because the altitude information of the 3DR & DJ I UAV will be provided to the PI C via GPS equipment and a radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path. This altitude information, combined with Lo reto Innovation ’s operation of the 3DR & DJ I UAV within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121. The altitude information will be generated b y GPS equipment installed onboard the aircraft. Prior to each f light, a zero al titude initiation point will be established and confirmed for accuracy b y the UAS PI C. The FAA has previously

granted relief from Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138). **5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not Adversely Affect Safety.**  A grant of this exemption would ensure an equival ent level of safety established by

14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the 3DR & DJ I ; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly , Lor eto Innovation will ensure that it can safel y operate the battery powered 3DR & DJ I UAV during daylight hours, in VFR conditions, for a total flight duration of no more than 15

- 20 minutes, resulting in a landing with five minutes of battery power remaining

. In a previous Petition for Exemption, in which an operator was utilizing a UA identical in all material respects to the 3DR & DJ I Lo reto Innovation proposes to use, the FAA granted an exemption from the requirements of Section 91.151, stating as follows : In the event that the UAS should run out of power, it would simply land within the access controlled operating area. Given its weight and construction material, the risks are less than contemplated b y the current regulation. Prior relief has been grante d for manned aircraft to operate at less than the minimums prescribed in § 91.151 (a), including Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS

- specific relief has been granted an Exemption Nos. 8811, 10808, and 10673 for day time, Visual Fl ight Rules (VFR) conditions. The 3DR & DJ I provides a battery

failsafe that commands the UA’s return to the launch point when critical minimum voltage is reached. The UAS batteries provide approximately 20

- 25 minutes ofpowered flight. The FAA agrees with Clayco’s proposal to limit UAS flights to not more than 30

minutes, or enough battery reserve to ensure that the UAS lands at the ground station with at least 20% battery

reserve power, whichever happens first. Given the limitations on its proposed operat ions and the location of those proposed operations, a reduced minimum power reserve for flight in daylight VFR conditions is reasonable. See Exemption No. 11109 at 15. Here, as in Exemption No. 11109, the technical specifications of the 3DR & DJ I ; the limitations on the proposed flight operations; and the location of the proposed operations, will ensure that Loreto Innovation may

safel y operate the battery powered 3DR & DJ I UAV during daylight hours in VFR conditions for a total duration of not more than 20 minutes, and landing with five minutes of battery

power remaining. Significantl y, previous exemptions granted b y the FAA concerning Section 91.151 establish that safet y is not adversely affected when the technical characteristics and operating limita tions of the UAS are considered. Relief has been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief from Section 91. 151 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138). **6. Reasons Why An Exemption Fr om** **The Requirements Of Sections 91.405(a),**  **91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety**

. In seeking this exemption, Lo reto Innovation submits that the equivalent level of safet y with regard to the regulatory m aintenance and alteration requirements established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because Loreto Innovation will use its trained technicians to perform maintenance, alterations, or preventive mai ntenance on the unmanned aircraft sy stem using the methods, techniques, and practices prescribed in the manufacturer’s maintenance manual. Furthermore, Loreto Innovation will document and maintain all maintenance records for the 3DR & DJ I

. Since the 3DR & DJ I will be inspected as prescribed by the manufacturer’s maintenance manual, Lo reto Innovation will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). The Flight Manual for the 3DR & DJ I sets forth airworthiness requirements for the UA, including preflight and post flight inspections, as well as scheduled maintenance in four categories: dail y, weekl y, monthly, and ye arly

. Likewise, the exemption sought will not adversel y affect safety because Lo reto Innovation will perform maintenance, alterations or preventive maintenance on the UAS using the methods, techniques, and practices prescribed b y the manufacturer’s maintenance manual. The Flight Manual for the 3DR & DJI details procedures for each compone nt of the UA, including the components of the propulsion system, avionics s ystem, and payload sy stem. A complete description of the 3DR & DJ I airworthiness and maintenance requirements is set forth in the “ the “ 3DR Manual ” & “DJ I Manual” attached hereto as Exhibit A & B . ExhibitA & B contains proprietary information and is to be held in a separate file pursuant to 14 C.F.R. § 11.35(b). Furthermore, the exemption sought would maintain an equivalent level of safety established by

Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the 3DR & DJI will be performed b y Lo reto Innovation trained technicians, who will document and maintain maintenance records for the 3DR & DJ I

. In consideration of Lo reto Innovation ’s proposed operating limitatio ns, the most recent 3DR & DJ I 6 Flight Manual, and the technical aspects of the 3DR & DJ I , Loreto Innovation submits that safety

will not be adversely

affected by

granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previousl y granted relief specific to UAS in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11110, 11112, 11136, 11138).
**7 . The FAA May Prescribe Any Other Conditions For Safe Operation** 

. In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 29 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, Lo reto Innovation requests that the FAA prescribe special conditions for the intended operation of the 3DR & DJI , which contain such safet y standards that the Administrator finds necessary to establish a level of safet y equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113 (a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the UA for the limited purpose of conducting aerial acquisitions over certain areas of the Un ited States. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security ; and further, provides the authority for such UAS to operate without airworthiness certification in accordance with any requirements that must be established for the safe operation of the UAS in the NAS. Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for operation of the 3D R & DJ I , since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusual design features of the aircraft. Section 21.16, entitled Special Conditions, states the following:
If th e FAA finds that the airworthiness regulations of this subchapter do not contain adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller because of a novel or unusual design feature of the aircraft, aircraft engine or propel ler, he prescribes special conditions and amendments thereto for the product. The special conditions are issued in accordance with Part 11 of this chapter and contain such safety standards for the aircraft, aircraft engine or propeller as the FAA finds nec essary to establish a level of safet y equivalent to that established in the regulations. See 14 C.F.R. § 21.16. Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special conditions for Loreto Innovation ’s intende d operation of the 3DR & DJ I , whichcontain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).
**F. Summary That Can Be Published In The Federal Register, stating: The Rules From**  **Which Loreto Innovation Seeks Exemption:** Loreto Innovation, Inc. seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a )(2), and 91.417(a) & (b). A Brief Description Of The Nature Of The Exemption Loreto Innovation Seeks: This exemption will permit Lo reto Innovation, Inc. to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial data capture and water samples over areas of the United States.
**G. Any Additional Information, Views, Or Arguments Available To Support**  **Loreto Innovation’s Request.**  This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS may operate safely

in the NAS. As such, Loreto Innovation ’s request for exemption may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness certification. As discussed in detail above, Lo reto Innovation will operate the 3DR & DJI safel y in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national security. **CONCLUSION** As set forth herein, Loreto Innovation seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the 3DR & DJ I commerciall y, without an airworthiness certificate, for the limited purpose of conducting aerial acquisitions over areas of the United States. By granting this Petition, the FAA A dministrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing Loreto Innovation to safel y, efficientl y, and economicall y operate the 3DR & DJ I commerciall y within the NAS.
**WHEREFORE** , in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, Lo reto Innovation respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) &(a)(2), and 91.417(a) & (b), and permit Loreto Innovation to operate the 3DR & DJ I

commerciall y for the purpose of conducting aerial d ata capture. Dated: June 5, 2015 Respectfully

submitted, Loreto Innovation, LLC

. Que El

- Amin | 4200 North Holton Street, Milwaukee, WI 53212 | 414

- 797

- 1828

Appendices: Appendix A: 3DR APM Hexacopter Instruction Manual Appendix B: DJI

Spreading Wings S900 Instruction Manual Appendix C: Monthly Maintenance Lo g

Appendix A3DR: http://3drobotics.com/wp

- content/uploads/2013/06/3DR

- APMCopter

- Hexa

- Assembly

Instructions1.pdf

Appendix B

DJI: http://www.manualslib.com/manual/836421/Dji

- Spreading

- Wings

- S900.htmlAppendix C

**UAS	#**

**__________________ Date	Issue** 

**Discovered Date	Issue** 

**Addressed Item	Description	&** 

**Maintenance	Conducted Maintenance**  **Performed	By**
**Software Updates** **Airframe**

**Engines Propellers**  **Camera Gimba**  **l Landing	Gear**  **Vibration Dampening**  **Other:**